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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
The penalty-only pre-deposit proviso to section 112(8) of the CGST Act applies prospectively from 1 October 2025. The text states that, because the impugned appellate order predated that effective date and the amendment did not expressly or necessarily imply retrospective operation, the pre-deposit condition could not attach to a substantive right of appeal arising from proceedings instituted earlier. Accordingly, no pre-deposit was required for admission of the penalty-only GST appeal, without affecting the merits or any direction at final hearing.
The penalty-only pre-deposit proviso to section 112(8) of the CGST Act applies prospectively from 1 October 2025. The text states that, because the impugned appellate order predated that effective date and the amendment did not expressly or necessarily imply retrospective operation, the pre-deposit condition could not attach to a substantive right of appeal arising from proceedings instituted earlier. Accordingly, no pre-deposit was required for admission of the penalty-only GST appeal, without affecting the merits or any direction at final hearing.
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